Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Disallowance of software expenses - Disallowance is in respect of expenditure claimed towards “repairs - computers-annual maintenance” and “Repairs-computers-others” - AO has treated it as capital expenditure on the reasoning that it was towards purchase of licenses and allowed depreciation at the rate of 25% - even if the expenditure is treated as capital, depreciation would be allowable at the rate of 60%
Disallowance of software expenses - Disallowance is in respect of expenditure claimed towards “repairs - computers-annual maintenance” and “Repairs-computers-others” - AO has treated it as capital expenditure on the reasoning that it was towards purchase of licenses and allowed depreciation at the rate of 25% - even if the expenditure is treated as capital, depreciation would be allowable at the rate of 60%
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